Reminder: In June of 2018 EPA required that regulated products (composite wood articles such as hardwood, plywood, MDF, and particleboard) manufactured or imported into the U.S were required to be certified as TSCA Title VI (or CARB ATCM Phase II in the case of California) compliant. This regulation was due to recently introduced formaldehyde emission standards. Approximately 450 HTS are subject to the requirement. A list of those HTS codes is available on the EPA website.
As of March 22, 2019, importers, manufacturers, and retailers of composite wood products must certify that their articles conform to the new standards. This is accomplished by filing a TSCA statement with each shipment, signed by the importer.
The statement must read “I certify that all chemical substances in this shipment comply with all applicable rules or orders under TSCA and that I am not offering a chemical substance for entry in violation of TSCA or any applicable rule or order under TSCA”.
The name, phone number, and email address of the certifier must be included on the TSCA form.
Please contact us for an updated copy of the Formaldehyde TSCA statement.
Note that in addition to the labeling requirement, commercial documents such as the bill of lading, commercial invoice must include a written statement from the supplier certifying that the goods are TSCA Title VI, or CARB ATCM Phase II compliant.
Manufacturers of these products must have their products tested by an EPA authorized Third Party Certifier (TPC), and conduct quality control tests on a regular basis.
If you are an importer of these types of products you should confirm with your suppliers that they have obtained the testing, are labeling the cargo according to the regulation, and providing the written statement on the commercial documents.
Please visit the EPA’s Formaldehyde website for additional information or contact your V. Alexander account team.